Doc #: 1000-AD-015-0028 Revision: - GLOBALLY HARMONIZED SYSTEM (GHS) SOP Author(s): T. Lavoie/ M. Saucedo/ J. Dunlop/ Supervisor
TABLE OF CONTENTS REVISION HISTORY... 3 1.0 INTRODUCTION... 4 2.0 PROGRAM DESCRIPTION... 4 3.0 DEFINITIONS... 4 4.0 HAZARDS ASSOCIATED WITH GHS... 4 5.0 CONTROL OF HAZARDS... 5 5.1 Administrative... 5 5.2 Elimination/Substitution... 5 6.0 RESPONSIBILITIES... 5 6.1 Supervisor... 5 6.2 Employees/Contractors... 5 7.0 PROCEDURES... 5 7.1 GHS Overview... 5 7.2 Label Requirements... 5 7.3 Label Elements... 5 7.4 Training... 7 8.0 REFERENCES... 7 1000-AD-015-0028.Docx Page 2 of 7
REVISION HISTORY Rev Date Approved Sections Affected Reason for Change Remarks and/or Change Details Name -- mm-dd-yy Initial Release T. Lavoie Approved by: John Dunlop John Dunlop, Facilities Manager Larry Reddell Larry Reddell, Mountain Facilities Supervisor Tammie Lavoie 28 November 2017 Tammie Lavoie, Safety Manager Date 1000-AD-015-0028.Docx Page 3 of 7
1.0 INTRODUCTION This policy will pertain to all NOAO-North employees and contractor personnel who work with or around areas containing health, physical, and environmental hazards. This policy outlines the acceptable safety measures for the classification, and labeling of chemicals according to the GHS regulations that fall under the revised Hazard Communication Standard, 29 CFR 1910.1200. 2.0 PROGRAM DESCRIPTION This policy covers the basic knowledge that workers need in order to be in compliance with the updated Hazard Communication Standard. 3.0 DEFINITIONS GHS Globally Harmonized System HCS Hazard Communication (HAZCOM) Standard KPNO Kitt Peak National Observatory NOAO National Optical Astronomy Observatory OSHA Occupational Safety and Health Administration Pictograms Graphic symbols that are used to communicate specific information about the hazards of a chemical. SDS Safety Data Sheets 4.0 HAZARDS ASSOCIATED WITH GHS The OSHA has identified health, physical, and environmental hazards as the categories for all occupational illnesses and injuries that fall under the GHS standard. Due to the broad nature of these categories, and depending on the type and route of exposure, workers must become familiar with all GHS components. 1000-AD-015-0028.Docx Page 4 of 7
5.0 CONTROL OF HAZARDS 5.1 Administrative All employees and contractors must review this document upon hire, and refresh, as needed. Training requirements must be reviewed in section 7.4. 5.2 Elimination/Substitution When possible, workers should substitute hazardous chemicals for products of lesser risk. 6.0 RESPONSIBILITIES 6.1 Supervisor Ensure that persons within their areas of responsibility comply with this policy and its implementing documents, and, in particular, have completed the required training prior to beginning work. 6.2 Employees/Contractors Follow all guidance provided in training and work processes to safely adhere to the recent GHS regulations that fall under the revised Hazard Communication Standard, 29 CFR 1910.1200. 7.0 PROCEDURES 7.1 GHS Overview OSHA has revised the HCS to align with the requirements of the United Nations Globally Harmonized System of Classification and Labeling of Chemicals. The changes that are made in this standard will ensure quality, consistency, and worker comprehension when labeling hazardous chemicals. 7.2 Label Requirements Per the definition of the HCS, labels are classified as written, printed, or graphic informational elements concerning a hazardous chemical that are affixed to, printed on, or attached to the immediate container of a hazardous chemical, or to the outside packaging. Labels must be legible and easy for workers to locate. Labels must be written in English, and other languages may also be included. 7.3 Label Elements The revised HCS does not require a standard format for labels. However, to remain in compliance, all labels must meet the minimum information requirements. The following information components must be included on all hazardous chemical labels: Name, Address, and Telephone Number The name, address, and telephone number of the chemical manufacturer, importer or other responsible party must be listed in a clear, legible manner. 1000-AD-015-0028.Docx Page 5 of 7
Product Identifier The product identifier is how the hazardous chemical is identified. Some examples of product identifiers include, but are not limited to, the code number, batch number, and chemical name. The most important part of the product identifier is that it must be on the chemical label as well as in the first section of the SDS. Signal Words There are two signal words, Danger and Warning, that specify how severe a hazard is. Danger identifies the most severe hazards, and Warning identifies the least severe hazards. There will only be one signal word on the label, regardless of how many hazards are in a chemical. In the event that Danger and Warning are both applicable to a hazard, Danger must be the only signal word used. Hazard Statements Hazard statements are phrases that describe what type of hazard, or hazards, are present. One example of a hazard statement is Causes damage to kidneys through prolonged or repeated exposure when absorbed through the skin. All hazard statements that are applicable must be present on the chemical label. Precautionary Statements Precautionary statements are phrases that notify the reader of the necessary measures to prevent or minimize any adverse effects that occur through the exposure, improper storage, or mishandling of a chemical. The four categories of precautionary statements are prevention, response, storage, and disposal. Safety Data Sheets Safety Data Sheets are formerly known as Material Safety Data Sheets (MSDS). Under the revised HCS, chemical manufacturers, distributors, and importers must provide SDS for each hazardous chemical. Generally, the SDS provides the same information as the MSDS did. The main difference is the 16-section format. For a complete list of these sections, please visit https://www.osha.gov/publications/osha3514.html. Supplementary Information If needed, the label manufacturer may provide additional instructions, suggestions, or hazards that are not otherwise classified under the label. Additionally, the percentage of toxicity must also be identified when it is present in a concentration that is greater than, or equal to, 1%. Pictograms are also considered supplementary information. The GHS has recognized and implemented nine pictograms, and OSHA is enforcing all of them except for the Environmental pictogram. The picture listed below demonstrates the symbol, written name, and hazards associated with each pictogram. 1000-AD-015-0028.Docx Page 6 of 7
7.4 Training The employer shall provide training to ensure the purpose and function of this program is both understood by workers, and the knowledge and skills required for the safe application of all GHS components are acquired by workers. Retraining must be provided when there is a change in job assignments, equipment, or processes, or when changes have been issued by governing authorities. 8.0 REFERENCES The above information can be found at the following links: OSHA Brief: Hazard Communication Standard- Labels and Pictograms https://www.osha.gov/publications/osha3636.pdf OSHA Brief: Safety Data Sheets https://www.osha.gov/publications/osha3514.html OSHA https://www.osha.gov 1000-AD-015-0028.Docx Page 7 of 7